The What IF Plan is a trading name of DNA PLan Limited.
DNA Plan (company registration 11225404) is committed to protecting and respecting your privacy.
For the purpose of applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”), the company responsible for your personal data is DNA Plan Limited (“DNA Plan Ltd” or “us”).
This policy (together with DNA Plan’s terms and conditions and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
“Service/s“, denotes DNA Plan’s service and the Site (including graphics, text, images and other information featured on the Site).
“Research“, denotes scientific research. The intent of data gathered for research is to establish a scientific database for research purposes. DNA Plan only uses genetic data and information reported by users who have given their consent to share their genetic data and information in accordance with DNA Plan LTD’s terms and conditions (referred to above) and this policy.
For the purpose of the General Data Protection Act 2018 (the Act), the data controller is DNA Plan of 2nd Floor 5 High Street, Westbury On Trym, Bristol, Avon, BS9 3BY.
[Our nominated representative for the purpose of the Act is Kate Llewellyn-Waters.
What Personal Information The What If Plan Gathers
“Personal Information”, means information that can be used to identify the user, alone or in conjunction with other information. DNA Plan gathers the following types of Personal Information (see also the terms and conditions (referred to above):
“Registration Information”, includes personal information you supply when registering for the Services on the Site or by corresponding with us by phone, e-mail or otherwise. The information you supply may include your name, address, e-mail address and phone number, financial and credit card information, personal description, saliva samples, and self-reported information including medical conditions, ethnic origin.
“Genetic Data and Information”, means data and information related to your genotype, generated through the analysis of your saliva by DNA Plan or by its assigned contractors.
“User Content”, means information provided by users of the Site that does not include Personal Information. This information is distributed publicly or privately, to or through DNA Plan.
DNA Plan does not provide services to anyone under the age of 18 years and therefore does not knowingly collect, process, share or store such data. Whilst we take all reasonable precautions to ensure users are over 18 should we identify a user to be below this age then all agreements will be terminated, services removed and any data will be deleted.
How your Information is Handled
DNA Plan gathers Personal Information from you to provide the Services, which includes the delivery of the Service, presenting new services, offering the opportunity to be involved with research projects, acquiring testimonials for promotional purposes; performing quality control checks and becoming involved with research. DNA Plan will always ask for your consent to collect and handle your Personal Information.
Combined Collected Genetic Data and Self-Reported Information
DNA Plan aims to contribute to increasing scientific evidence, DNA Plan users can contribute and partake in this.
The use and value of Genetic Data and Information and other Personal Information containing genetic and medical data increases when it is assessed and evaluated against the Genetic Data and Information and relevant Personal Information of other individuals (“Combined Collected Genetic Data and Self-Reported Information”). All assessments are carried out using anonymised Personal Information and DNA Plan takes measures to protect your Personal Information and ensure it remains private.
DNA Plan may disclose to third parties Combined Collected Genetic Data and Self-Reported Information. DNA Plan will take sufficient action to ensure that the Combined Collected Genetic Data and Self-Reported Information is non-identifiable, so that the information is not able to be used, either alone or in conjunction with other information available, to identify an individual or to associate an individual to any specific data. DNA Plan will also employ contractual measures with third parties it shares your Personal Information with to protect the privacy and security of your Personal Information and the Combined Collected Genetic Data and Self-Reported Information.
If you have given your consent for your Personal Information to be used in research as defined in the consent section on the Site, we can deliver this information to researchers who may utilise it for research, which may be published in peer-reviewed scientific journals. If you have given your consent to participate in research we can authorise researchers to analyse your Personal Information for scientific research. Except as stipulated above, DNA Plan will never disclose your Personal Information to a third party without receiving informed consent from you, unless we are obliged to by law.
Disclosure of Information
We will not share your Personal Information with any third party, except to the following:
- any member of The What If Plan group, which means its subsidiaries, its ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006;
- vigilantly-screened partners or service providers, such as the contracted laboratory or credit card processors who process the Personal Information in order for DNA Plan to provide the Services;
- if you have consented for research and researchers to analyse your Combined Collected Genetic Data and Self-Reported Information online for scientific research purposes, then to such researchers;
- in the event that The What If Plan sells or buys any business or assets, in which case it will disclose your Personal Information to the prospective seller or buyer of such business or assets;
- if DNA Plan or substantially all of its assets are acquired by a third party, in which case your Personal Information will be one of the transferred assets; and
- if DNA Plan is under a duty to disclose or share your Personal Information in order to comply with any legal obligation, or in order to enforce or apply DNA Plan’s terms and conditions and other agreements; or to protect the rights, property, or safety of DNA Plan, its customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
In the event that DNA Plan is obliged by law to make a disclosure, DNA Plan will contact you, unless DNA Plan is prohibited from doing so by law.
Providing your Personal Information is voluntary and based only on the express consent you give.
Giving consent to DNA Plan to use your Personal Information for research is entirely voluntary.
You may withdraw your consent at any time by notifying customer services (email@example.com).
You have the right to ask DNA Plan not to process your Personal Information for marketing purposes. DNA Plan will inform you (before collecting your Personal Information) if it intends to use your Personal Information for such purposes or if it intends to disclose your Personal Information to any third party for such purposes.
[The Site may, from time to time, contain links to and from the websites of DNA Plan’s partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that DNA Plan does not accept any responsibility or liability for those policies. Please check those policies before you submit any personal data to those websites.]
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request will be subject to a reasonable fee to meet our costs in providing you with details of the information we hold about you.
Security and Where We Store Your Personal Data
DNA Plan is dedicated to maintaining the faith and trust, which you enlist in DNA Plan. So that prohibited access or disclosure does not occur, and to preserve the accuracy of information, and to guarantee that Personal Information is used correctly and appropriately. DNA Plan employs numerous physical, technical, and administrative measures to keep your Personal Information protected. Specifically, connections to our website are encrypted using Secure Socket Layer (SSL) technology.
Unfortunately, the transmission of information via the internet is not completely secure. Although DNA Plan will do its best to protect your Personal Information, it cannot guarantee the security of your Personal Information to our site; any transmission is at your own risk. Once DNA Plan has received your Personal Information, it will use strict procedures and security features to try to prevent unauthorised access.
This policy may change at any time in the future. When changes are made to this policy, you will be notified either through our website or services, or by email if appropriate. Please revisit your account and/or this page regularly as if you continue to use the Services and the Site after the date of the change, you will be regarded to have consented to the changes to this policy.
If you do not consent to the changes, you have the option of ending your relationship with DNA Plan by contacting us at firstname.lastname@example.org and must stop using the Services and the Site.
Your Control Over Your Personal Information
If you no longer wish to use the Services, you can email customer services (email@example.com). On receiving this email, DNA Plan will remove your Personal Information as soon as reasonably possible.
If there are any changes in your Personal Information, you can update them by email to customer services (firstname.lastname@example.org).
You have the right to obtain access to your personal data any time by emailing your request to email@example.com. We will contact you to confirm your identity before any disclosure. We will provide this within one month of your request or two months for complex requests.
How to Contact DNA Plan
Questions regarding this policy or how DNA Plan handles your Personal Information can be emailed to firstname.lastname@example.org.